Public Consultation Responses on the draft
TAN8Analysed by the Cambrian Mountains Society

1. The Cambrian Mountains Society has announced the results of its
comprehensive analysis ofthe responses to the Welsh Government's public
consultation on the draft Technical AdviceNote 8 (TAN 8). The final version
of this controversial document led to the proposals for theestablishment on
the uplands of Wales of what Welsh Government consultants called'turbine
landscapes'. As a result of their analysis the Society is calling for a new
review ofTAN 8.

2. Only 10% of respondents supported the draft TAN 8 in what is thought to be
the largestnumber of responses to any Welsh Government consultation. 90% of
the close to 1700responders were against the whole or part of TAN 8. The
responses were notable for thenumber of individuals who responded, rather
than organizations. 94% of these responseswere against TAN 8 in whole or
part. Their views were almost wholly ignored in the finaldocument.

3. Despite the overwhelming opposition to the draft document the final TAN 8
was if anythingstrengthened further in favour of turbine development on the
Welsh uplands.

4. Many responders criticised the timing of the Consultation and local
community councils whoresponded complained that they were left out of the
formal arrangements. The draft waspublished just days before, under the
Welsh Government's own regulations, the need for aStrategic Environmental
Assessment of such a policy came into effect on 21st July 2004. Callsfor TAN
8 to be the subject of a Strategic Environmental Assessment owing to its nature
andscale were not answered by the Welsh Government.

5. Despite the views of the vast majority of responders to the Consultation,
landscape qualitywas not considered in the selection of areas for turbine
development other than to rule outNational Parks and AONBs. Remarkably the
Countryside Council for Wales (CCW) was notinvolved until the public
consultation stage. Thus areas which CCW as the WelshGovernment's statutory
adviser on landscape classifies as of outstanding landscape qualityare
categorized in TAN8 for turbine developments and a future as 'turbine
landscapes'. Evena prospective wind turbine developer's response was to
express unease about turbinesbeing proposed 'very close to the nationally
acclaimed Pumlumon range'. This has caused agreat deal of public anxiety
about the policy.

6. On the important issue of grid transmission National Grid Transco
expressed particularconcern that it had not been considered in the planning.
The Welsh Government's responsewas that the issue had to be considered
outside TAN 8. This is analogous to constructing areservoir without any
consideration of where the main water pipes have to go. It has a
directrelevance to the problems in Mid Wales to-day and which contributed to
the largest everdemonstration outside the Welsh Assembly in Cardiff last
summer.

7. Other problems arising from the current application of TAN 8 were
envisaged by many of theresponders. In their responses turbine developers
referred to problems of transmission anddifficulties of access on public
roads.

8. The work underpinning the document was undertaken by international
consultants Arupwho considered it would apply for 5-7 years. Since that
report turbine heights haveincreased from around 160 feet to around 450
feet, public perceptions have developed onthe issue and other technologies
have developed too as well as the UK government's energypolicy. Problems
have arisen on transmission and other issues. The Cambrian MountainsSociety
therefore calls for the Welsh Government to instigate a formal review of
theapplication of TAN 8 and to apply to it the Strategic Environmental
Assessment which itsown regulations would normally require.

1. The controversial policy on establishing wind turbines and associated
transmission lines inthe Welsh uplands is based on the Welsh Government's
TAN 8 (Technical Advice Note 8) thebasis of which has been recently the
subject of criticism in the Welsh Assembly, in Parliamentand was the cause
of this summer's largest demonstration ever outside the Welsh Assemblyin
Cardiff

2. The Cambrian Mountains Society have analysed the responses to the public
consultation onthe draft Tan8 circulated in July 2004 and have produced the
only numerical analysis of theresponses. The analysis was carried out by 8
analysts from the Cambrian Mountains

Society who between them examined each of close to 1700 responses to
theconsultation.

3. The results of the analysis show the overwhelming opposition to TAN8
expressed in theconsultation responses. Responders' comments are as relevant
to-day as at the draft stageof Tan8.

4. Further detail on the Cambrian Mountain Society's analysis and pdf files
containing theresponses can be viewed at